CASP Authorisation in Greece
Greece is an HCMC-supervised EU CASP route under MiCA for teams that want Greek or Eastern Mediterranean positioning with EU/EEA market-access planning. It is useful for regulated CASP operations, but it still requires real substance, governance, AML, audit and banking readiness.
Confirm current HCMC MiCA/CASP application requirements, forms, fee schedule, transitional rules and supervisory practice before using this page for client advice.
Regulatory status should be confirmed by local counsel before relying on this route.
What is Greece CASP authorisation?
Greece CASP authorisation is the HCMC-supervised EU route for crypto-asset service providers under MiCA. It is relevant for teams that want a regulated EU base with Greek or Eastern Mediterranean positioning and can maintain a financial-services-grade operating model.
- Jurisdiction
- Greece
- Regulator
- Hellenic Capital Market Commission (HCMC)
- Regime
- CASP
- Legal basis
- Legal basis: MiCA CASP authorisation under the Greek/HCMC supervisory framework, subject to current local implementation.
Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.
CASP service scope in Greece
The Greece file should start with a precise MiCA service perimeter. Exchange, custody, brokerage, wallet, advisory, staking-adjacent and payment-related activity can each change the evidence expected for governance, safeguarding, AML, outsourcing and banking.
Exchange
ConditionalExchange activity may require additional scope or separate licensing.
Exchange
Exchange activity may require additional scope or separate licensing.
ConditionalCustody
ConditionalCustody may require separate review or additional controls.
Custody
Custody may require separate review or additional controls.
ConditionalBrokerage
ConditionalBrokerage or OTC activity typically fits within scope.
Brokerage
Brokerage or OTC activity typically fits within scope.
ConditionalWallet provider
ConditionalExchange activity may require additional scope or separate licensing.
Wallet provider
Exchange activity may require additional scope or separate licensing.
ConditionalEU market
IncludedEU/EEA passporting available.
EU market
EU/EEA passporting available.
IncludedStartups
ExcludedHigh setup complexity means significant budget is needed.
Startups
High setup complexity means significant budget is needed.
Excluded
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
EU/EEA passporting from Greece
Greece can be used as an EU home member state route for MiCA CASP authorisation. The passporting plan should be connected to authorised services, target countries, client categories and the notification process rather than treated as a generic marketing claim.
Define target EU/EEA markets and distribution channels before filing.
Map each intended passporting market to the exact CASP services requested in Greece.
Use Greece for EU access and regional Mediterranean positioning only if the team can maintain the required governance, substance and controls.
Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.
Capital, governance and audit expectations
The CSV snapshot positions Greece as a high-complexity route with share capital from 50,000 EUR, an approximate 5,000 EUR state fee, an approximate 3,000 EUR annual supervision fee, required local staff, physical office and audit. The main cost is maintaining the regulated operating model after authorisation.
- Board, senior management, compliance, AML, risk, technology and custody ownership should be named and credible.highBoard, senior management, compliance, AML, risk, technology and custody ownership should be named and credible.high
- Capital planning should match the selected CASP services, especially for exchange, custody, staking or fiat-heavy operations.highCapital planning should match the selected CASP services, especially for exchange, custody, staking or fiat-heavy operations.high
- Audit, reporting, outsourcing oversight, safeguarding and incident-management workflows should be budgeted as recurring obligations.highAudit, reporting, outsourcing oversight, safeguarding and incident-management workflows should be budgeted as recurring obligations.high
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Greece CASP application bottlenecks
Most Greece CASP blockers are operating-model issues. The route works best when service scope, local substance, governance, AML, audit and banking are solved before the application is treated as a timeline exercise.
- High
Unclear CASP service perimeter or passporting plan
- High
Weak local governance, staffing or board accountability
- High
Custody, safeguarding, wallet or technology-control evidence that does not match the product
- High
Generic AML policies that do not reflect clients, tokens, geography and fiat flows
- High
Banking or PSP package prepared after the application strategy
- High
Route selection driven by a low-budget or fast offshore objective rather than an HCMC-supervised EU operating model
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Activity fit for this route
Review which crypto activities fit within the scope of this route.
Exchange activity may require additional scope or separate licensing.
Custody may require separate review or additional controls.
Brokerage or OTC activity typically fits within scope.
Exchange activity may require additional scope or separate licensing.
EU/EEA passporting available.
High setup complexity means significant budget is needed.
Not sure if your model fits? Request a licensing assessment
Is Greece CASP authorisation right for your project?
Best for
- EU passporting and regulated CASP operations
- EU/EEA market access
Not suitable for
- Low-budget or fast offshore setup
- Projects without a prepared banking strategy
Banking difficulty is high for this route. Prepare a banking strategy before committing to the Greece route.
Core requirements
Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Local substance in Greece
Local staff and a physical office should be treated as operating requirements. A nominal Greek address is not enough if key decisions, compliance ownership, custody oversight and regulator-facing accountability sit elsewhere without a defensible control model.
Local staff
RequiredRequired
At least one locally-accountable staff member or director is expected.
Physical office
RequiredRequired
A genuine office presence is expected, not a nominal registered address.
Audit
RequiredRequired
External audit is required for ongoing supervision compliance.
Planning notes
- Define which governance, AML, risk and operational responsibilities sit in Greece.
- Document group outsourcing, technology providers, custody infrastructure and board oversight before filing.
- Budget local staff, office, audit and ongoing compliance separately from the application advisory fee.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Cost breakdown
Budget for service price, regulatory fees, share capital and ongoing costs separately.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Cost breakdown — Greece
Budget for service price, regulatory fees, share capital and ongoing costs separately.
| Cost item | Amount |
|---|---|
| Service priceApplication preparation and professional services. | €19,700 |
| State fee | €1 |
| Required share capitalMust be held, not an expenditure. | €50,000 |
Summary
- One-off costs
- €69,701
- Annual (year 1)
- €0
- Total year 1
- €69,701
Adjust to convert to your base currency.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Application process
The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Greece — From 6 months.
Pre-assessment and scope review
1–3 weeksDefine the activity scope, governance model and target markets before formal preparation.
Company setup in Greece
2–6 weeksEstablish legal entity, appoint local staff and set up local operating structure.
Documentation and compliance packBottleneck risk
3–8 weeksPrepare AML/CFT policies, governance documents, controls framework and application materials.
Application submission to Hellenic Capital Market Commission
1–2 weeksSubmit complete application with all required documentation.
Regulator reviewBottleneck risk
From 6 monthsRegulator reviews the application. May request clarifications. Incomplete files extend this phase.
Depends on: File quality and completeness
Authorisation or registration confirmation
1–4 weeksRegulator confirms authorisation or registration. Commence operations.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
What can delay or increase cost
These factors are most likely to affect timelines and budgets for this route.
Setup complexity is rated high for Greece. Company setup, governance and documentation take longer than average.
Banking difficulty is rated high. Opening accounts for crypto businesses in Greece requires extensive documentation.
Ongoing supervision, audit and compliance costs are above average. Budget for these separately from the application fee.
Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Banking and PSP strategy
Greece has a high regulatory reputation in the CSV profile, but crypto banking difficulty remains medium to high. Bank, EMI, PI and PSP readiness should run in parallel with the CASP application, especially for exchange, custody and fiat-heavy models.
Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.
Reflects availability of payment service providers willing to onboard crypto-licensed entities.
A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.
Preparation checklist
- Prepare ownership, source-of-funds, flow-of-funds, client geography, token policy and transaction monitoring evidence early.
- Explain safeguarding, custody, reconciliation and fiat rails before approaching banks or PSPs.
- Do not assume HCMC authorisation or passporting will automatically solve account opening or payment rail access.
Business model fit — Greece
Assess how well this route covers your planned activities.
Fit score
- Good fit
- 0/6
- Partial fit
- 6/6
- Poor fit
- 0/6
Greece may not cover your primary activities
Consider an alternative route that better matches your activity profile.
HCMC application profile
Hellenic Capital Market Commission (HCMC)
An HCMC-facing CASP file should read like a regulated financial-services application: precise services, accountable management, local substance, AML controls, safeguarding, technology resilience, outsourcing oversight and banking readiness.
- Greece is strongest for teams that value EU authorisation with Greek or Eastern Mediterranean market credibility.
- Custody, exchange and cross-border fiat flows need deeper controls than narrow brokerage or advisory models.
- AML, sanctions, travel rule, transaction monitoring, outsourcing and cybersecurity materials should be product-specific.
- Current HCMC practice and Greek MiCA implementation should be checked before relying on filing mechanics, fees or timing.
Strong international recognition and established supervision track record.
Reflects documentation depth, governance requirements and expected review friction.
Reflects likelihood of delays, additional information requests or policy uncertainty.
Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.
Compliance documentation
Most crypto licensing routes require a documented compliance framework before submission, not only after approval.
- RequiredAML/CFT policy and risk assessmentDocument your customer risk model and control framework.
- RequiredCustomer due diligence (CDD) procedures
- RequiredEnhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
- RequiredTransaction monitoring system and rules
- RequiredSanctions screening procedures
- RequiredSuspicious activity reporting (SAR) process
- RequiredMLRO / Compliance officer appointmentLocal accountability may be required.
- RecommendedBoard-approved governance charter
- ConditionalOutsourcing policy and monitoringRequired if functions are outsourced.
- RecommendedICT / cybersecurity policy
- RequiredComplaints handling procedure
- RequiredAnnual external audit engagementRequired for ongoing supervision compliance.
Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.
Documents to prepare
Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.
Corporate documents
AML and compliance
Operational
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Risk assessment
Main risk dimensions for the Greece route.
Route risk rating — banking difficulty: Medium to high. Authorisation does not guarantee bank account opening.
Mitigation: Start banking outreach and compliance preparation before the application.
Route risk rating — setup complexity: High.
Route risk rating — maintenance cost: High. Budget for ongoing compliance, fees and supervision separately.
Route risk rating — regulatory reputation: High.
Route risk rating — regulatory risk: Low to medium. Weak compliance, vague scope or insufficient controls increase review risk.
Mitigation: Prepare an evidence-based compliance file before submission.
This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.
Greece CASP vs alternatives
Compare Greece with Cyprus CASP for a nearby EU financial-services hub, Bulgaria CASP for a regional EU cost comparison, Italy CASP for larger Southern Europe market signalling, and Malta CASP for a more established EU/MiCA crypto supervision profile.
Greece
CASP
- Price
- 19 700 EUR
- Timeline
- From 6 months
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- High
Cyprus (CASP)
CASP
- Price
- 17 000 EUR
- Timeline
- From 6 months
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- High
+ Nearby EU financial-services hub with CySEC supervision
− Also requires MiCA-level governance, substance, AML, audit and banking readiness
View routeBulgaria (CASP)
CASP
- Price
- 19 600 EUR
- Timeline
- From 6 months
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- High
+ Regional EU option with a practical cost profile
− Current FSC practice and local implementation should be validated before relying on timing or fees
View routeItaly (CASP)
CASP
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- High
+ Large Southern Europe market signal for MiCA/CASP positioning
− May be heavier for teams that do not need Italian market credibility or a larger-market regulator profile
View routeMalta (CASP)
CASP
- Price
- 20 700 EUR
- Timeline
- From 6 months
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- High
+ Established EU/MiCA crypto supervision profile with MFSA experience
− Not a low-cost or low-substance alternative to Greece
View routeFees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Greece vs other CASP routes
Compare key parameters across CASP authorisation routes.
Check your readiness for Greece CASP authorisation
Documented AML/CFT policies, risk assessment, compliance officer.
From 50 000 EUR minimum capital required.
Documented AML/CFT policies, risk assessment, compliance officer.
Board, management, accountability chain defined.
Banking strategy and identified partners.
Local staff and office in Greece.
Readiness status
Answer the criteria on the left to see your readiness status.
Frequently asked questions
Greece CASP authorisation under MiCA can support EU/EEA passporting for authorised services, subject to the required notification process. It should not be described as automatic access for every future product, token, client segment or market.
Greece is best suited for teams that need an HCMC-supervised EU CASP route, want Greek or Eastern Mediterranean positioning, and can support real local substance, governance, AML, audit and banking readiness.
Usually no. The route requires share capital, local staff, physical office, audit, governance, AML controls and ongoing compliance, so it is not suitable for a fast offshore setup or low-substance launch.
Check the exact CASP service scope, HCMC filing requirements, local management and staffing model, audit plan, AML controls, custody or safeguarding arrangements, outsourcing structure and banking or PSP readiness.
Compare Cyprus for a nearby EU financial-services hub, Bulgaria for a regional EU cost comparison, Italy for larger Southern Europe market positioning, and Malta for an established EU/MiCA crypto supervision profile.
The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.
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